The system for delivering new development does not meet our needs. It makes the rich richer while failing to deliver the housing and other land uses the majority require, or the infrastructure to support them. Instead of being guided by communities, development is led by a rapacious market responding to socially-harmful incentives. This section introduces some of the issues: incentives that favour speculators over public need, a concentrated housebuilding sector that fails to deliver quality, speed or affordability, and the inability of local authorities and communities to take control.
Many of the problems with the British housing system can be traced to a reliance on private developers operating on a speculative model of development. The duty of these companies is to their shareholders, and they shape the built environment in ways that maximise shareholder value. In many cases, the result is buildings, tenures and amenities that bear little resemblance to those that communities need.
Taking back control means creating a new model, in which development is led by democratically-accountable bodies with a duty to serve the public interest, working in partnership with local people, landowners and others. It also means empowering residents to help design their homes and surrounding infrastructure, putting people at the heart of development.
This involves a shift from a system dominated by developers to a more dynamic system, characterised by constructive tension between democratically-elected bodies and direct community engagement. Local authorities will be forced to engage communities as early as possible to avoid later disputes. Communities will need to recognise that the more influence they wield, the greater their responsibilities to meet future needs, even where these needs threaten existing land uses. There will be disagreements, which will not always be easy to resolve, but this is the essence of democracy.
The driving force of development is profit rather than places
New development should be based on recognising communities’ goals, identifying suitable land to meet them, and ensuring sites are prepared with the necessary infrastructure. At present, however, it is dominated by the pursuit of huge windfall gains by landowners. This means that the wrong sites are often selected, with inadequate provision for infrastructure, and often at great environmental cost, while landowners and land promoters capture fantastic profits at public expense. The interests of wealthy landowners overwhelm communities and local government.
Private windfalls, public squalor
In modern economies, the value of a plot of land depends on what can legally be built on it, and the infrastructure and amenities in the surrounding area. Development rights in the UK are nationalised, meaning that government controls development on behalf of the public. The granting of planning permission typically generates a large increase in the value of the land (known as ‘planning gain’). So do new transport links and other infrastructure. The question of who gains the benefit from rising land values, and how this is used, has sat at the centre of land debates for centuries.
Early classical economists, such as Adam Smith and John Stuart Mill, objected to the ability of landowners to make windfall gains at the expense of wider society. They considered returns earned from the ownership of land to be unjust and inefficient – referring to these windfalls as ‘economic rent’. In the UK, various mechanisms have attempted to recover increases in land value arising from the granting of planning permission.
In 1947, the Labour government introduced a development charge, stipulating that 100% of the increase in value arising from the granting of planning permission should be paid to the state. The charge was widely criticized for discouraging new building, and many landowners withheld their sites from development in the hope that a future government would repeal the charge, which the incoming Conservative government swiftly did in 1952. Over the following decades, governments made further attempts to use taxation to recover land value uplift – including the Betterment Levy in 1967, the Development Gains Tax in 1973 and the Development Land Tax in 1976. But none persisted.
Today the main tools for securing uplift for the public sector are ‘developer contributions’ through Section 106 agreements (Section 75 agreements in Scotland), and the Community Infrastructure Levy (CIL). While these are essential tools for local authorities, they fail to recover the majority of land value created by the granting of planning permission and development, in particular because developer contributions are agreed case-by-case, and local authorities lack the resources and powers to drive a hard bargain. Landowners can delay development in the hope of smaller obligations in future. A recent study by the Centre for Progressive Policy suggested landowners made a post-tax windfall profit of £10.7bn in 2016-17 compared to £5bn secured for the public. These figures suggest that an extra £214bn could be recovered for the public over the next 20 years. These are only estimates, as the data required to produce a definitive answer are still not available, as discussed in Chapter 2.
This means the majority of uplifts go into private hands. Not only does the public lose, but this system ensures that the market is dominated by speculation, not building. To take back control of development, we need to give democratic bodies and communities powers to drive development and recover increases in land values for public benefit.
Development should be led by the public interest
Development is currently dominated by a small number of companies, and a land purchasing model that drives prices up. We need a public interest-led system, in which public bodies determine what land is developed, and insist on development that respects ecological limits, while delivering quality, affordable housing. This section first outlines the problem with the current system, then makes the case for Public Development Corporations with new powers to assemble sites.
Speculation drives up land values and drives down quality
The failure to secure land value uplift for the public combines with the problems explained in Chapter 3 to create huge incentives for speculation on land. This situation arises not from individual failures, but from a policy environment that creates a profit model based on privatising the maximum amount of uplift.
The process by which developers and land promoters purchase land drives up land values. Developers typically employ a ‘residual valuation methodology’ to arrive at an offer price for a parcel of land. This involves estimating the final sales value the developer expects to receive from the new homes, then subtracting the expected costs of building them, to leave a residual amount. The price offered for the land must come from this residual value. The developer with the most bullish expectations of house prices and their own ability to drive down Section 106 contributions will offer most, and secure the site. This model causes higher development costs for the supply of new homes.
Paying such high prices for the land forces developers to cut costs in other areas. Seeking cuts means paying lawyers and planning consultants to outmuscle local authorities, to drive down their Section 106 contributions towards infrastructure or affordable housing. Though recent attempts have been made to tackle this issue, the problem will persist while policy and resources favour developers over the public sector.
This system of buying land creates a strong incentive to cut costs when designing and building new homes, resulting in poor quality housing. More money spent on land means less money spent on design and building.
Developers are under structural pressure to constrain overall production
Once land has been secured, developers cannot risk releasing too many homes at once. Doing so might reduce house prices in the area, lowering the value of the land the developer has bought. The incentive to keep house prices high by releasing new homes slowly impedes the necessary step change in the number of homes being built.
This system also ensures that development is highly cyclical. When house prices fall, developers suspend land acquisition and cut build-out rates swiftly to reduce costs and avoid selling into a falling market. When house prices are rising, developers must compete to secure suitable land, causing greater volatility in land prices.
This is compounded by, and causes, a lack of diversity in the building sector
Small- and medium-sized (SME) housebuilders delivered nearly 40% of new homes in 1988, but only 12% in 2016. The financial crisis hit them hard, but they have also been forced out by several centralising tendencies in the market. The improved access to finance and lower costs associated with economies of scale, the scale of the land banks held by the leaders and lack of transparency around land holdings all make it difficult for new entrants and SME housebuilders to compete. This lack of competition helps the major house builders to limit the supply of homes to keep prices high.
The lack of small builders limits self-building, which could make a significant contribution to overall output. Some estimates suggest self-build accounts for over half of all new builds in France, Austria, Belgium and Germany. In the UK, by contrast, it accounts for around 7-10%. This is not through lack of demand: around half the population expresses an interest in building their own homes. Self-build can have major environmental and social benefits, and ensure that housing meets the needs of those who will use it.
Preparing new sites using Public Development Corporations
Purchasing land and preparing it for development can be a complex, risky and time-consuming process. To ensure that enough land is made available and assembled for new development, new public and democratically-accountable Development Corporations should be established with the power to purchase, develop and sell land in the public interest.
These Development Corporations would not replace private developers altogether, but would act as the prime mover in the land market, working with planning authorities, Homes England and landowners to prepare sites for new housing developments, new towns, garden cities and urban regeneration projects. Once land has been assembled, the Development Corporations would contract out construction to housebuilders, prioritising local small- and medium-sized firms, who would compete with each other on the basis of quality and design of house building. This means that the success or failure of private developers would be determined by construction quality rather than by their ability to navigate the speculative land market.
When combined with reforms to compulsory purchase laws (see below), such public bodies can also ensure that land value uplift is retained by society. This is how the New Towns programme, which began in 1946, operated. For each New Town, a public development corporation was established which purchased land compulsorily at agricultural prices, drew up a comprehensive masterplan for the town, then built the necessary infrastructure using money borrowed from the Treasury. They granted planning permission on the sites they owned and sold them to private house builders or local authorities, using the uplift in the value of the land to repay their loans. This system was crushed in the 1960s through legislative changes demanded by landowners lobbying the Conservative Government.
The new Development Corporations must also be able to borrow at low cost. We propose that the Regional Development Banks that Labour has promised to establish should provide long-term, patient finance to the Development Corporations, to enable the purchase of land at low cost.
Compulsory purchase reform
Reform of land compensation law will help strengthen democratic control over development. In most rich nations, including the UK, the state has the power to acquire rights over land without the owner’s consent, in return for compensation, under compulsory purchase powers. In the UK these powers emerged in the nineteenth century to prevent landowners from blocking the construction of new railways. They have also played an important role in the past in ensuring an adequate supply of affordable housing, in particular by enabling the state to retain more of the land value uplift arising from new development. This method is currently used to great effect in other countries.
For example, in Hong Kong, the Mass Transit Railway (MTR) has become one of the world’s leading railway operators through its ‘Railway + Property model’. The Mass Transit Railway Corporation (MTRC) buys land at existing use value, builds rail infrastructure and accompanying developments, then leases the surrounding land to businesses at prices that reflect the presence of the railway and adjacent developments. Though ticket prices are low by world standards, it is one of the most profitable railway systems in the world. Rather than requiring public subsidy, the MTRC contributes significantly to the public purse.
Under the current legal framework, public authorities in the UK are prevented from purchasing land at close to existing use value. Lobbying by landowners resulted in The Land Compensation Act 1961 (in Scotland, the Land Compensation Act 1963). This reinstated the principle that landowners are entitled to ‘hope value’ on any land compulsorily purchased. In practice, this means that where public authorities wish to purchase land for development, landowners are compensated not on the basis of what the land is worth at the time, but on the basis of what it one day might be worth if it acquires residential planning permission.
Because the difference between existing use value and hope value is usually massive, these changes significantly increased the cost of land for development, and ended the ability of public authorities to deliver cheap land for new housing. In other words, the changes meant that the benefits from rising land values flowed to landowners rather than the general public.
Reinstating the ability of public authorities to acquire land at near use value could potentially transform the land market. This would mean that public authorities, rather than the landowner, would retain the uplift in the value of land, unlocking significant funds for infrastructure and other public goods.
- A Labour Government should reform land compensation law. This would require making relatively small amendments to Sections 14-16 of the 1961 Land Compensation Act so that no account is taken of prospective planning permissions when compensating owners for land designated for housing and infrastructure.
Although this relates to compulsory purchase orders (CPOs), in reality few CPOs would need to be issued. Evidence from the UK’s past and from equivalent countries shows that the very existence of strong compulsory purchase powers can be sufficient to shift the balance of incentives in the land market. Aware that the land could be purchased by the state at near use value, landowners would be encouraged to part with land at a low but fair price. This could have the powerful dual effect of increasing the supply of land and lowering the market price by reducing landowners’ ability to profit from hope value.
An analysis by Daniel Bentley for Civitas estimates that such a change could reduce the cost of building affordable housing by 50% on greenfield sites in the South East, or by 33% in the case of a high-density apartment blocks in London.
Empowering local government to take back control
Public development corporations have an important role to play, but development must ultimately be controlled by elected local government. We need to give local authorities the resources and powers to regain control of land use.
Why local authorities cannot control development
Years of funding cuts and a deregulatory environment have left many local planning authorities without sufficient capacity and power to ensure that land meets our needs, and to stand up to deep-pocketed developers. Planning authorities have been hit even harder by austerity than other public bodies. The National Audit Office reported a 53% reduction in funding for planning and development services in local authorities between 2010-11 and 2016-17.
The ability of local authorities to control development has been further diminished by housing targets and permitted development rights. Successive ministers have blamed planning delays and ‘red tape’ for a failure to deliver new housing, but the corresponding reforms have removed power from local areas.
- Ambitious targets for identifying land for housing have made it difficult for local authorities to reject inappropriate housing developments. At the moment, local authorities are forced to adopt a presumption in favour of development where they have not met targets. This obliges them to bypass the wishes of communities expressed in local plans, and accept developments even where there is insufficient provision for housing standards or infrastructure. Moreover, these targets are based on housing demand rather than identified local needs, such as for affordable or special needs housing;
- Permitted development rights take certain decisions out of councils’ hands entirely by ensuring certain types of development do not need normal planning permission. This lack of control stops local planning authorities being able to maintain housing standards. It also means they cannot collect developer contributions or secure affordable housing quotas. And they challenge both local authorities’ and communities’ ability to control local development.
To make matters worse, developers have been granted asymmetric powers. They use their right to re-submit planning applications and their rights of appeal (which objectors do not possess) to grind down local people’s resistance.
A lack of funding from central government, combined with a refusal to allow local authorities to set their own planning fees, council tax rates and levels of borrowing, has forced local authorities into an unhealthy reliance on developer contributions to meet key objectives, especially the delivery of affordable housing. By 2016/17, 68% of all developer contributions in England were for affordable housing, with a decreasing proportion going to other assets like transport and open spaces. This emphasis ensures that the infrastructure required to serve new developments is often underfunded and the contributions still aren’t sufficient to meet the need for genuinely affordable housing.
How to return power to local authorities
Local authorities should lead local development both by using public land and by purchasing and assembling new sites. Many local authorities are already resuming this role, either directly or through vehicles like wholly-owned housing companies and joint ventures. These and other approaches must progress rapidly if development is to work for the many.
Local authorities should play a key role not just in new housing development, but also in providing the other assets communities need. This means setting aside land for parks, wildlife refuges and public amenities demanded by communities, as discussed in Chapter 7. It means protecting or restoring rich living systems, while providing space for recreation and exercise and reducing carbon emissions. It means helping to provide social infrastructure, like schools, hospitals and playgrounds that glue communities together.
To deliver all this, local authorities need new powers and resources to engage in placemaking and active co-creation of policy and development with communities. They need the power to stand up to developers and retain the maximum amount of land value uplift through Section 106 agreements.
The capacity of planning authorities is partly dependent on a new funding settlement for local authority finances. Planning is a public service. It should be funded as such, rather than relying on income from developers. In particular, the proposal for council tax reform in Chapter 3 should leave local authorities in a far stronger position to support effective planning. To further enable local authorities to reclaim control of development, we propose the following additional policies:
- Each local authority should be able to set its own planning application fees above a national minimum. This should include the ability to vary fees. For example, fees could be increased where applications are submitted more than once, particularly where advice has been not been followed, or policy has been ignored. This would not only help raise crucial income to improve planning, but could also shift the balance of power away from deep-pocketed developers;
- Local authorities should be required to set housing targets based on identified local housing needs, rather than simply responding to national targets based on demand. This should consider the type, size and tenure that local people need and can afford as well as national targets for new social housing;
- Local planning authorities should be supported to assemble and prepare sites for development. These could be provided on land already owned by the authority, land purchased by the authority, or through partnership with landowners. If purchasing the land, compensation reforms such as those described above would help. Local authorities would prepare the site, delivering the required infrastructure, then either develop the site or sell it and acquire the uplift;
- Government should remove permitted development rights that allow office and agricultural buildings to be turned into housing without the need to apply for permission. These often lead to poor quality housing without an affordable component, and restrict the ability of communities and their representatives to shape development. They also lead to the uncontrolled loss of workspace and therefore remove control over planning from councils.
Ending the sale of public land
While the measures described above should help public bodies assemble new sites for development, they should also make the best use of sites we already own. A recent study suggests that 10% of the land in Britain has been sold by the public sector since Margaret Thatcher came to power. Local authorities have often been selling land to plug budget deficits, rather than using it to meet social needs. Only 20% of new homes planned for public land that has been sold recently will be affordable. As the IPPR Commission on Economic Justice recently proposed, we need to end this scandal.
- The sale of public land should end. Local authorities and other arms of Government should use the land they own to deliver high-quality affordable housing and meet other key social, environmental and economic needs. Where appropriate, public land could be leased to others who can help meet these needs.
Real power for communities to guide development
Our goal is not just to transfer power from the market to the state. We also we need to grant local people and communities genuine powers and resources to shape the land around them.
The nationalisation of development rights should mean that communities have a stake in controlling development. This means granting communities influence over both individual developments and planning policy: for example through neighbourhood and local plans. Indeed, of all areas of government, the land use planning system provides perhaps the greatest opportunities for participation in decision-making.
Many planners already work very hard to engage communities, despite serious financial challenges. But most people perceive that they have little influence. They have far less time and resources than the builders and landowners, who stand to make immense profits from rising land prices and development. Democratic deficits can particularly afflict decision-making on national infrastructure. Major roads can be proposed – and championed by bodies such as Highways England and the National Infrastructure Commission – before meaningful public consultation occurs.
To energise community participation in decisions about land use we suggest the following five steps:
- A formal review of community participation in planning, with a mandate to move away from tick-box exercises towards genuine co-creation of policy and developments;
- Establish an independent body, the Community Participation Agency, with a mandate to involve communities and under-represented groups in planning at every level;
- Introduce jury service for planning to ensure a wide range of people can influence plan-making;
- Make information on land use and planning accessible to everyone.
- Introduce a new Future Generations Champion or Team in each local authority.
A review of public participation in planning
50 years after the publication of the Skeffington Committee report on public participation in planning, we need a system that reflects its findings and permits real co-creation. Therefore the first step we recommend is a formal review to explore what needs to happen to energise community participation in planning. This review could build on the work of Labour’s existing Planning Commission led by Roberta Blackman-Woods MP, which is already “Examining how local communities can better provide the building blocks of our planning system, and take ownership of planning policies that will affect them.” It could also be added to the mandate of the Land Commissions proposed in Chapter 2.
Such a review should consider how to enable a genuine transfer of power to local people, identifying ways to facilitate early engagement using modern methods. It should identify how to guarantee regular and transparent communication, with a particular emphasis on how to build public trust, for example by clearly explaining why any suggestions or complaints from the public are not upheld.
The review should examine historical attempts to improve community participation as well as international examples. Examples in England include the previous Labour Government’s Local Strategic Partnerships and Sustainable Community Strategies and more recent reviews such as the TCPA’s Raynsford Review of Planning in England. It could also learn from the recent protocol for ‘Community Engagement in Decisions Relating to Land’ developed by the Scottish Land Commission. This protocol sets out general principles for community engagement and specific requirements for everyone involved in decision-making about land use. Finally, it could consider international examples such as the participation-centred planning framework in the National Resources Act in New Zealand and digital participation tools used in Reykjavík, Iceland.
The Community Participation Agency
The second step we recommend is to establish a new agency with a mandate to give all sectors of the local community influence over local planning. This could be an independent national body, with a federated structure to ensure it can promote participation at a local level. This would make it clear that community participation is a priority, and something worth resourcing. It could be partly funded by drawing on land value uplift recovered from developments in the area – especially since areas with more development would need more engagement.
The Community Participation Agency should also find ways to help future tenants participate in the design of new housing. Rather than just blocking development they perceive to be unsuitable, communities could have a positive role in shaping new places. Where the development is led by the public sector, the relevant body should endeavour to give future communities a stake in its design. This would include new social housing development. The Chairman of the Local Government Association recently argued that future tenants could play a major role in designing new social housing. We would go further, proposing that future tenants should have input not only into the housing they might occupy, but also on the layout and amenities of the development.
The Community Participation Agency should also secure the participation of citizens in major infrastructure planning. As recommended in the Institute for Government’s 2017 report, it could be modelled on the French Commission Nationale du Débat Public, with a mandate to facilitate community participation and debate. In line with the Aarhus Convention, this should take place at the earliest possible stage.
Jury service for planning to broaden participation
Any attempts to increase community participation in planning must also recognise that there is seldom, if ever, a homogenous local community. Loud voices can dominate, especially those of the most privileged. Many voices – in particular those who lack social power – typically go unheard. The planning system should seek to take everyone’s interests into account, especially those who have not been involved before.
Therefore we recommend introducing jury service for planning as a third step towards energising and diversifying engagement in planning. Just as we believe it is important for criminal juries to be socially representative, the way we use our land should have input from all parts of society. Juries for plan-making would be comprised of local people selected at random. They would participate in designing local and neighbourhood plans at the earliest possible stage.
Making information on the planning process accessible to everyone
Public participation in planning is also challenged by the difficulty of finding and understanding information on planning policy and decisions. Quality data is essential to proper community participation in land use planning, but there is currently an imbalance between what developers and communities can see.
This is why the fourth step we recommend is requiring that planning applications and development plan policy data should be published in a simple, consistent way, with geospatial boundaries under open licensing. As discussed in Chapter 2, this must also come with better data on ownership, options and developers’ records.
Securing the needs of children and future generations
Future generations will live with the consequences of development, good or bad. However, neither children nor future generations are able to represent themselves in the planning process. This leads to the routine neglect of their interests. Issues like air pollution and climate breakdown will have huge impacts on communities of the future, yet they are given insufficient attention today.
Therefore, the fifth and final step we recommend is to introduce a Future Generations Champion or Team in each local authority (or regional authority where appropriate). This Champion would represent the interests of children and future generations in planning decisions and plan making. The Champion would bring to the fore potential impacts of development that might not be felt immediately, such as climate breakdown and the loss of ecological function and integrity. The Champion would also ensure that children’s voices are heard in the planning process, and are able to shape decisions affecting their wellbeing, such as the use of public space.
The mandate of the Future Generations Champions could be agreed in national and local planning policy. It could draw on:
- The Wellbeing of Future Generations (Wales) Act 2015, which requires public bodies to “act in a manner which seeks to ensure that the needs of the present are met without compromising the ability of future generations to meet their own needs”;
- UNICEF’s Children’s Rights and Urban Planning Principles – 10 principles which support children’s development and protect future generations.
The Champion would be a statutory consultee on local plans and major developments. It could include local citizens and experts on long-term need.Next: Chapter 6: Community-led development and ownership of land »
 For an assessment of historic attempts at recovering land value in the UK see: C. Jones et al, 2018. An assessment of historic attempts to capture land value uplift in the UK, The Urban Institute, Heriot-Watt University.
 For more information on these tools, see Chapter 2 of: Housing, Communities and Local Government Committee, 2018. Land Value Capture.
 T. Aubrey, 2018. Gathering the windfall: how changing land law can unlock England’s housing supply potential, Centre for Progressive Policy.
 Where developers are confident that they can wriggle out of their contributions to affordable housing and infrastructure, and/or are willing or able to cut corners on build quality, this will also lead to inflated land bids.
 A similar conclusion was reached in the Conservative’s own recent review of build out: O. Letwin, 9th March 2018. RE: Independent review of build out: preliminary update, MHCLG and the Treasury, letter to P. Hammond and S. Javid.
 P. Jefferys et al., 2014. Building the Homes We Need, KPMG & Shelter.
 Ministry of Housing, Communities & Local Government, 2011. A Housing Strategy for England.
 For more on the history of compensation reforms, see: D. Bentley, 2018. Land of Make Believe: Compensating landowners for what might have been, Civitas.
 Local Government Association, 2018. Local Government Association response to the MHCLG consultation on the ‘Draft revised National Planning Policy Framework’.
 Clifford et al., 2018. Assessing the impacts of extending permitted development rights to office-to-residential change of use in England, RICS Research Trust.
 See Raynsford Review Task Force, 2018. Planning 2020: Raynsford review of planning in England, final report, TCPA, for more information on how this might be implemented.
 B. Clifford, 2018. Assessing the impacts of extending permitted development rights to office-to-residential change of use in England, RICS Research Trust.
 C. Roberts, 2016. Start me up: The value of workspaces for small businesses, entrepreneurs and artists in London. IPPR.
 B. Christophers, 2018. The biggest privatisation you’ve never heard of: land, The Guardian.
 W. Brett, 2018. Selling public land is making the housing crisis worse, New Economics Foundation.
 IPPR, 2018. Prosperity and Justice: a plan for the new economy, Final report of the IPPR Commission on Economic Justice. See also: Luke Murphy, 2018. The Invisible Land, IPPR Discussion Paper, IPPR.
 G. Monbiot, 2018. This disastrous new project will change the face of Britain, yet no debate is allowed. The Guardian, August 2018.
 Raynsford Review Task Force, 2018. Planning 2020: Raynsford review of planning in England, final report, TCPA.
 Scottish Land Commission, 2019, Community Engagement in Decisions Relating to Land, Land Rights and Responsibilities Protocol Series.
 New Zealand Ministry for the Environment, Getting involved in council plans and plan preparation processes, RMA processes and how to get involved, (Resource Management Act website).
 Information on digital participation in Reykjavík and other international examples of participation can be found in Simon et al, 2017. Digital Democracy: the tools transforming political engagement, Nesta.
 For more information on the issues involved in setting up such a body, see G. Parker and E. Street, 2018, Enabling Participatory Planning: Planning aid and advocacy in neoliberal times, Bristol: Bristol University Press.
 An interesting model for one way this might work was recently proposed in: A. Parvain and A. Reeve, 2018, Affordable Land. The Self-Build and Custom Housebuilding Act 2015 and the Right to Build Taskforce, provide other opportunities which could be expanded.
 D. Slade and N. Davies, 2017. How to design an infrastructure strategy for the UK. Institute for Government.
 The United Nations Economic Commission for Europe (UNECE), 1998. UNECE Convention on Access to Information, Public Participation in Decision-making and Access to Justice in Environmental Matters (Aarhus Convention).